Evidence has been presented that a
witness, <insert name of witness>, made [a] statement[s] outside of court
that (is/are) inconsistent with (his/her) trial testimony. You should consider
this evidence only as it relates to the credibility of the witness's testimony,
not as substantive evidence. In other words, consider such evidence as you
would any other evidence of inconsistent conduct in determining the weight to be
given to the testimony of the witness in court.

[<Include
if appropriate:> The law treats an omission in a prior statement as an
inconsistent statement.]

Commentary

Inconsistencies are not limited to diametrically opposed statements, but include
omissions and denials of recollection. State v. Simpson, 286 Conn. 634,
649 (2008).

The court is not required to give a
specific instruction concerning inconsistent statements when the inconsistencies
are not substantial and do not relate to a material matter. State v. Herring,
55 Conn. App. 522, 526 (1999), cert. denied, 252 Conn. 941 (2000).

This instruction should be tailored
to the evidence of the case. See State v. Ramirez, 94 Conn. App. 812,
823-25 (2006) (the court did not improperly marshal the evidence by pointing out
inconsistencies in testimony because it reminded the jury that credibility was
up to them).